Modern slavery statement

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Introduction

Section 54 of the Modern Slavery Act 2015 requires larger employers to produce a modern slavery statement for each financial year.

The Jigsaw Homes Group (’the Group’) was founded in April 2018 from the merger of Adactus Housing Group and New Charter Housing Trust. It has a turnover of £190m, employs over 1,400 staff and manages more than 34,000 homes located in the North West of England and the East Midlands. The Group’s business is primarily centred around the provision of social housing and associated services:

  • Management and letting of properties
  • Development of new homes
  • Repair and maintenance of housing stock and estates
  • Revenue collection
  • Money and welfare advice
  • Charitable donations to individuals and groups
  • Supporting victims of domestic abuse
  • Supporting vulnerable and/or client groups from disadvantaged backgrounds.

The Group and its subsidiaries trade only in the UK and not in any countries where the Group considers there to be a high risk of trafficking and modern slavery.

The Group’s Modern Slavery Statement for 2019-20 is set out below.

Statement 2019-20

This is the Jigsaw Homes Group’s Modern Slavery Statement for 2019-20:

The Group is absolutely committed to preventing slavery and human trafficking in our activities and to ensuring that our supply chains are free from slavery and human trafficking and we will put in place arrangements to ensure there is no slavery or human trafficking in our own services, in our businesses and in our supply chains.

Responsibility

This statement is approved by the Group Board.

The Executive Management Team (EMT) is responsible for overseeing anti-slavery initiatives, led by the Deputy Chief Executive & Group Company Secretary.

The Group’s managers have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them are given adequate and regular training on the issue of modern slavery in supply chains.

The prevention, detection and reporting of modern slavery in any part of the Group’s business or supply chains is the responsibility of all those working for the Group or under its control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.

The Group’s zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.

The Group may terminate its relationship with other individuals and organisations working on our behalf if they breach this policy.

Risk Management

The Group actively manages risk in line with its Risk Management Policy. The Group has determined that there are no areas of its business that are considered to be at high risk of slavery or human trafficking.

We maintain a comprehensive risk management framework and work closely with our Internal Auditors (TIAA).

Relevant policies

Complementary policies are:

  • Safeguarding
  • Health and Wellbeing
  • Financial Regulations
  • Scheme of Delegation
  • Recruitment and selection
  • Equality and Diversity
  • Probity and Anti Fraud
  • Employee Handbook
  • Non-Executive Handbook
Reporting Suspicions

The Group has strong links with other agencies through its participation in multi-agency community safety partnerships and safeguarding arrangements with the relevant local authorities where it has housing stock.

The Group requires Jigsaw employees to report any suspicions of trafficking or modern slavery. This can be done via its ‘concern card’ procedure. This procedure, which brings to the attention of the relevant Neighbourhood Safety Managers in the Group any safeguarding concerns, is communicated to staff via the mandatory safeguarding training provided to all staff by the Group’s Safeguarding Lead. The Group’s Safeguarding Lead has received training in reporting trafficking and modern slavery concerns.

The relevant Neighbourhood Safety Manager will take a decision as to whether the report merits contacting the local police. Employees may also contact the police direct where those who are committing such crimes or where victims are at risk merits an immediate 999 response, the Modern Slavery Helpline on 08000 121 700 or Crimestoppers on 0800 555 111.

Concerns may also be reported to the Deputy Chief Executive & Group Company Secretary.

No reports of trafficking or modern slavery concerns were reported in 2019-20.

Expectations of Suppliers and Due Diligence

The nature of our work means we engage with a diverse range of private and public sector organisations from local authorities, NHS trusts and the police to local and national businesses and tradespeople.

The Group is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Where appropriate our internal auditors will work with suppliers to ensure that they meet the required standards.

The Group uses employment agencies only by exception and when it does will only use specified, reputable employment agencies.

Jigsaw Homes Group undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. Responsibilities regarding procurement are as set out in the Group’s Financial Regulations. In terms of trafficking and modern slavery this means:

  • evaluating the modern slavery and human trafficking risks of each new supplier
  • conducting supplier assessments that focus on financial stability and cover insurance and compliance with various employment policies, with a greater degree of focus on slavery and human trafficking where general risks are identified;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
  • invoking sanctions against suppliers who fail to improve their performance in line with an action plan or who seriously violate our expectations of suppliers, including the termination of the business relationship.
Further Actions

Our aims for 2020/2021 are to:

  • Raise Awareness:
    • E-learning is to be rolled out to all employees;
    • Modern slavery will be included as a standing item on Jigsaw’s Safeguarding Group agenda
  • Strengthening Supply Chain Processes & Procedures
    • appropriate controls/expectations will be further embedded into processes and procedures in those areas of the business identified as higher risk such as asset management and HR.
Review and Publication

This policy and statement will be reviewed annually by the Group Board and published on the Group’s website.

Group structure
  • Jigsaw Homes Group Limited. Registered as a Community Benefit Society with FCA.
    Registration number: 29433R. Housing Regulator registration number: LH4345
  • Adactus Housing Association. Registered as a Community Benefit Society with FCA.
    Registration number: 16668R. Housing Regulator registration number: LH0131
  • Aksa Housing Association Limited. Registered as a Community Benefit Society with FCA.
    Registration number: 27003R. Housing Regulator registration number: LH3917
  • Beech Housing Association Limited. Registered as a Community Benefit Society with FCA.
    Registration number: 24230R. Housing Regulator registration number: SL3463
  • Chorley Community Housing Limited. Registered as a Community Benefit Society with FCA.
    Registration number: 30155R. Housing Regulator registration number: L4487
  • Jigsaw Homes Midlands. Registered as a Community Benefit Society with FCA.
    Registration number: 8378. Housing Regulator registration number: L4532
  • Jigsaw Support Limited. Registered as a Community Benefit Society with FCA.
    Registration number: 8241.
  • New Charter Building Company Limited. Company number: 3807120
  • New Charter Homes Limited. Company number 3807022. Charity Commission number 1146435.
    Housing Regulator registration number: LH4266
  • The registered office address for the above companies is Cavendish 249, Cavendish Street, Ashton-under-Lyne, OL6 7AT.
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